Mapfre
bd_0307c6c9ba7bc25d · schema v1 · pii pii-v2
Full breach record for Mapfre →Regulator's decision — not a breach notification
This record is a regulator's decision, not the organisation's own breach notice. Breach-notification fields (discovery date, notification clock) are structurally absent — what this source establishes is the outcome and the provisions the decision cites.
HHS OCR settled with MAPFRE Life Insurance Company of Puerto Rico for $2.2 million regarding the impermissible disclosure of unsecured ePHI. A stolen USB device containing names, DOBs, and SSNs of 2,209 individuals was left in an IT department without safeguards. Violations included failure to conduct risk analysis, implement risk management, and deploy encryption on laptops/removable media.
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Incident timeline — partial
? — ?
Breach window unknown
Jan 18, 2017
Filed
—
Corroborated · see linked filings
Compliance clocks stay unassessable until a breach filing is linked. This record is the regulator's action, not a breach notice. Dashed segments fill in automatically when corroboration arrives.
Linked disclosures
Why this link?Regulatory filings (1) · sorted by filing gap
- HHS OCRbd_1f0195c39e49788c2011-09-29 · +1938dCandidate
Filing propagation · 2 filings
View merged incident ↗Pattern: first filing Sep 29 (PR), last Jan 18 — a 1938-day rolling notification. Rolling spreads often mean counsel is filing as thresholds trip per state. Why this link?
Evidence ladder
Attacker assertion only. Establishes: claim date, group, alleged victim.
Unlocks: incident narrative, operational impact. Still no compliance clock.
Unlocks: discovery date, data types, affected count, compliance clock.
Unlocks: materiality, stated response, full audit trail. Ceiling removed.
Source ceiling
- instrument + outcome
- amount as filed (USD)
- CFR provisions
- the breach it recites
- discovery date
- notification clock
The dates the agreement recites belong to the underlying breach, years earlier, and are kept as evidence of WHICH breach rather than as this record’s timeline.